THROUGH 60 RELATE TO GLOBAL INVESTMENT PERFORMANCE STANDA...

Questions 55 through 60 relate to Global Investment Performance Standards.

Patrick Campbell Case Scenario

Patrick Campbell has just been hired as a consultant by Walter Investment Firm (WIF),

an asset management firm in operation since seven years. In order to gain a competitive

advantage in its industry, in March, 2010, the firm came into compliance with the Global

Investment Performance Standards (GIPS). WIF believes that being GIPS compliant will

increase their clients’ confidence in their investment performance results and will provide

them with an increased ability to compete in foreign markets. The CEO at WIF,

Christopher Carter, hired Campbell to analyze their investment reporting and calculation

methodologies, and to identify any errors that would prevent their compliance with the

GIPS. As part of his evaluation process, Campbell talked to Carter to gather some

information. Carter shared the following information:

WIF values portfolios on the date of all large external cash flows, and uses an

internally determined criterion to define ‘large’. Although this criterion requires

judgment and hence, is not documented, it is applied consistently from one period to

the next. WIF values composites every year using calendar year-end valuation dates.

The composite returns are calculated by asset-weighting the individual portfolio

returns.

The Growth Equity Composite includes two portfolios that have an objective of

earning a 2% excess return relative to a growth equity index fund including domestic

U.S. stocks. Both portfolios are managed using a semi-active management approach.

Exhibits 1 and 2 display information about the two portfolios.

Exhibit 1

Portfolio A

Date

Market Value ($)

Cash Flow ($)

Market Value After

Cash Flow ($)

05/31/09

495,000

06/13/09

550,000

135,000

06/22/09

715,000

06/30/09

867,000

Exhibit 2

Portfolio B

05/31/09

730,400

06/13/09

789,304

06/22/09

883,000

$65,000

06/30/09

1,450,394

The firm’s Market Oriented Composite invests in stocks that have P/BV and P/E

ratios equal to those of an average stock in the market. The composite includes a

number of portfolios, including both fee-paying and non-fee paying discretionary

portfolios. Some of the portfolios included in the composite are also part of other

composites offered by the firm. WIF makes no disclosure related to the non-fee

paying portfolios but they are subject to the same rules as fee-paying portfolios.

WIF also offers real estate and private equity investment vehicles to its clients. WIF

has invested a pension fund in direct real estate, and values this investment at market

value at least quarterly. In addition, when a presentation about the investment’s

returns is made to the board of the pension fund, WIF discloses the income and

capital appreciation component returns in addition to the total return, for the portfolio

investment, but not for the benchmark.

WIF’s maintains a real estate closed-end fund composite which commenced on 30

December 2009 with its first legally binding and closed capital call of $2,500,000. An

additional capital call was made on June 30, 2010 (Quarter 2) followed by two cash

distributions to the composite’s investors. The investors will receive ownership of the

portfolio’s assets at the end of the two years (31 December 2011). Exhibit 3 displays

some transactions that took place in the portfolio during the two years.

Exhibit 3

WIF’s Closed-End Fund Composite Transactions

Quarter

Additional investment

2

-$1,000,000

Cash distribution

4

$650,000

7

$490,000

Ending value

8

$4,200,000

In the real estate composite’s prospectus WIF has presented the composite’s since

inception internal rate of return (SI-IRR) calculated in accordance with the GIPS

provisions. The SI-IRR of the composite’s benchmark is quoted to investors on request.

The vintage year of the fund has been identified as 2009 in the fund’s prospectus.

55. Are Walter Investment Firm’s calculation methodologies most likely in

accordance with the Global Investment Performance Standards?

A.

Only with respect to composites.

B.

Both with respect to portfolios and composites.

C.

Neither with respect to portfolios nor with respect to composites.

56. The Growth Equity Composite return for the month of June based on the

beginning assets plus weighted cash flows method using the modified Dietz

method is closest to:

A.

45.39%.

B.

67.61%.

C.

53.20%.

57. With respect to the Market Oriented Composite, is WIF most likely in accordance

with GIPS?

A.

Yes.

B.

No, because GIPS do not permit firms to include a portfolio in more than

one composite.

C.

No, because the treatment of non-fee paying portfolios is not GIPS

compliant.

58. Is the treatment of the pension fund’s investment in direct real estate most likely

GIPS compliant?

B.

No, because real estate investments must be valued at market value at least

once every month.

C.

No, because the income and capital appreciation components must also be

disclosed for the benchmark.

59. Using Exhibit 3, the SI-IRR for the WIF real estate composite over the

measurement period, which is in accordance with the GIPS standards, is closest

to:

A.

6.4%.

B.

13.4%.

C.

28.1%.

60. Is WIF in compliance with the GIPS standards with respect to the details included

in the fund’s prospectus?

B.

Only with respect to the vintage year.

C.

Only with respect to presenting the composite’s SI-IRR.